Legal Seminar, Denver, CO

Combined Statistical Areas

• A Combined Statistical Area is a collection of adjacent Core-Based Statistical Areas that share substantial employment interchange. • New rule: A “local community” is any portion of a Combined Statistical Area that contains less than 2.5 million people. • Court’s ruling : Invalidated NCUA’s new interpretation. • A “local community” is a generally small area. • Combined Statistical Areas “stretch across vast regions that include multiple separate urban centers with suburban and rural communities.” • Residents in Combined Statistical Areas “may have no common bond at all beyond regional proximity.”

Adjacent Areas • New rule: A “local community” may include areas adjacent to a portion of a single political district, Core-Based Statistical Area, or Combined Statistical Area that a credit union demonstrates shares common interests or interactions with areas they already serve. • Court’s ruling : Upheld NCUA’s new interpretation from facial attack. • NCUA did not presumptively declare any particular “adjacent area” to be part of a “local community” • Credit unions must make case-by-case showing to NCUA that an “adjacent area” belongs to a local community. • Door open for individual challenges to particular expansions.